What is an Equality Impact Assessment
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Tameside & Glossop PCT Equality Impact Assessment Guidance What is an Equality Impact Assessment? An equality impact assessment (EIA) is the process of assessing the impact of existing or proposed functions or policies in relation to their consequences for equality target groups. This includes looking for both positive and negative impacts on equality target groups. The impact assessment process is an on- going process, and not a process that just happens once, and should develop and evolve alongside the functions and policies of the organisation. It involves anticipating the consequences of functions and policies and making sure that, as far as possible, any negative consequences are minimised and opportunities for promoting equality are maximised. The purpose of impact assessment process is to achieve improvements for equality target groups, so most well carried out impact assessments will require some form of action to be taken to bring about greater equality within the organisation. The outcomes of such actions are required to be monitored and reviewed as part of the ongoing equality impact assessment process. The nature and detail of the equality impact assessments will vary from assessment to assessment but it should not be seen as inherently difficult, or as an activity apart from other policy development and assessment work. Where does an EIA come from? Impact assessments originate from the Race Relations (Amendment) Act 2000 and recently, various other equality legislation has also stated that this process must be carried out as part of the public sector obligations within the law. The equality impact assessment should be seen in the context of both the specific and general duties described in the various pieces of legislation, which are: Race Relations (Amendment) Act 2000 Disability Equality Duty 2005 Equality Duty 2006 An authority (Tameside and Glossop PCT) subject to the specific duties within the above pieces of legislation is required to produce and publish a race, disability and gender equality scheme (Equalities Scheme) that includes a statement of the arrangements for assessing the impact of the Trust’s functions and policies, or the likely impact of its proposed functions and policies on equality target groups. The specific duties are, however, not an end in themselves, but designed to help authorities meet the general duty. The specific duty requirement to conduct impact assessments is designed to provide a mechanism for ensuring that due regard is given to race, disability and gender equality in the decision-making and the activities of the Trust. What are equality target groups? Tameside and Glossop Primary Care Trust defines equality target groups as: women, men, black and minority ethnic people, lesbians, gay men, bisexual people, trans people, young people and children, older people, disabled people and people from different faith groups. The equality areas or strands within the Trust are gender, disability, race, age religion or belief and sexual orientation. The strands are inclusive of all people. What is meant by ‘impact’? A negative or adverse impact: An impact that could disadvantage one or more equality target groups. This disadvantage may be differential, where the negative impact on one particular group is likely to be greater than on another. It should also be noted that some negative impacts may be intended. The EIA provides an opportunity to access this. The equality impact assessment process gives opportunity to assess this. For example: An event that was held in a building with no induction loop facilities would have a negative or adverse impact on some attendees with a hearing impairment. A positive impact: An impact that could have a positive effect on one or more equality target groups. This can involve improving equal opportunities and / or relationships between groups. This positive impact may differential, where the positive impact on one particular group of individuals or one equality target group is likely to be greater than on another. For example: A targeted training programme for black and minority ethnic women would have a positive differential impact on black and minority ethnic women, compared with its impact on white women and all men. It would not, however, necessarily have an adverse impact on white women or all men. This would have to be evidenced with the appropriate data. Who is responsible for carrying out EIA’s? Each policy and service lead within the Trust will take responsibility for identifying, functions, policies, strategies or projects that will need to be impact assessed. The service / policy leads will need to attend EIA training before they can conduct the screening exercise needed for each policy, function, strategy and project. When working on joint services, policies and strategies it is the policy / service lead that should raise the issue of needing to carry out an equality impact assessment with the partner organisations. The lead organisation in the group has the responsibility to initiate an EIA and carry it out with partner input. When should an EIA be carried out? An equality impact assessment (initial screening process) should be carried out when: Developing a new policy, strategy, function and project; Reviewing existing policies or changing existing policies; Those strategies, policies, functions or projects that have been prioritised and identified for EIA in year 1, 2 or 3 of the Equalities Scheme. All managers are responsible for incorporating equality into their work, which may be functions of the organisation, strategies, policies or projects, and for assessing the equalities impacts. This should be a continuous process, starting at the very beginning with assessing the need of the communities of Tameside and Glossop. If there is any doubt as to whether a function, policy, strategy or project requires the initial screening of the equality impact assessment process, then managers should contact the Equality and Diversity Manager. The EIA process consists of two parts: The initial screening process / template The Full Equality Impact Assessment if the initial screening process has identified an adverse / negative impact. The Initial Screening Process The initial screening process of a function or policy to see if the function and / or policy has any relevance to any of the equality target groups. Ideally this stage should be completed during the development or design of the function / policy before its goes to any group or committee for approval. If the function / policy is going to the Board for approval then it is a requirement of the Board that an impact assessment is carried out before it can go to the meeting. All functions and policies will be screened to find out if they need to have a full equality impact assessment conducted on them. Once the appropriate template (function / policy) has been filled out accordingly then a full equality impact assessment will only need to be conducted if: Any equality target group was identified as being disadvantaged or adversely / negatively impacted by the policy, strategy, function or project. The impact was assessed as of high importance any policy / service that has a major impact on the organisation at this screening stage, you should be assessing obvious negative / positive impact or gaps in the knowledge about likely impact. It should be a relatively short process, which makes use of: Demographic data and other statistics, including census findings recent research finding including studies of deprivation results of recent consultations and surveys results of the ethnicity monitoring data and any equalities data from local authority information from groups and agencies within Manchester comparisons between similar policies and functions analysis of PALS, complaints and public enquires information analysis of audit reports and reviews. A lack of the above information concerning a particular area should not be a reason to stop the impact assessment process. If a likely impact on a particular group is unknown or this information is not available then action needs to be taken to acquire this information. Completed screening templates (electronic copies if possible) should be sent to the Equality and Diversity Manager for their approval before a decision is made if the full equality impact assessment process should be embarked upon due to adverse / negative impact. See flowchart 1 – Screening Process. The Full Equality Impact Assessment This part of the process provides an opportunity to assess the evidence for a possible negative / adverse impact. It ensures that research and consultation with the equality target groups is carried out and leads to the improvement planning work to minimise or eradicate the negative impact. The process will involve the equality target groups, which can then recommend how to improve and eradicate negative impacts. During this process it will also ensure that consultation with the equality target groups is also completed. All of the impact assessment documents both initial screening templates and full impact assessment notes will be available to the public and will be published on the website. The publishing of the EIA’s is key to establishing accountability and maintaining public confidence and organisation transparency. This will also demonstrate that the organisation is committed to equality, whilst monitoring, assessing and consulting on the effects of the functions, policies, strategies and projects of the Trust. See flowchart 2 – Full Impact Assessment Process. What is a ‘function’ or ‘policy’ of Tameside and Glossop PCT? The Home Office and the Commission for Race Equality (CRE) have defined a policy as ‘any practice or written document which sets out a course of action, guiding principles or procedure which is adopted and implemented by the Authority. This includes any decisions taken or recommendations made at meetings which may lead to action to implement’. A ‘function’ is any activity of Tameside and Glossop PCT. A policy is any prescription, whether formal or informal, written or customary, on how a function should be carried out. As such it will include policies, strategies, guides, manuals and common practice, decisions that could lead to the formulation of a policy or practice. Support & Guidance The Equality and Diversity Manager is happy to give advice and support to individuals or teams in carrying out EIA. Please ensure that completed EIA’s are sent electronically (if possible) back to the team as soon as possible. The Access and Inclusion Team can also give information to the organisation around various aspects of Equality and Diversity, including equal opportunities and anti-discrimination. Equality Impact Assessment Training is delivered within the Trust by the Equality and Diversity Manager supported by the Education, Training and Development Team. Dates are rolled out throughout the year and the Equality and Diversity Manager will invite lead / senior managers to attend the training as appropriate. The training is a three hour session and will involve managers acquiring a knowledge of the current legislation, how to use the screening templates and considering equalities in everything that they do. Equality Impact Assessment Process Chart Screening Process Does the policy, strategy or service meet the criteria to require an EIA? Yes No further action required until review or change in policy / service Discuss the proposal with the Equality and Diversity Co-ordinator to get advice on how to include equality and diversity issues Screening pro-forma to be carried out by service/ policy lead or team Has an adverse / negative impact been identified? No Yes Fill in action plan within pro-forma in order to minimise low Full Equality Impact Assessment impacts and promote required equality. Full Equality Impact Assessment not required isseminateood N.B If a member of staff is unsure about any stage of the EIA process then the EIA guidance handbook should be referred to or the Equality and Diversity Co- ordinator should be contacted. Equality Impact Assessment Process Chart Full Impact Assessment Process Full Equality Impact Assessment required EIA Panel process set up between lead managers and equalities representatives Questions asked by panel to managers in order to explore adverse impacts of policy, strategy or service Solutions identified to promote equality and address any adverse / negative impacts Action plan agreed and implemented Performance review date agreed and added to performance accelerator Publication of EIA N.B If a member of staff is unsure about any stage of the EIA process then the EIA guidance handbook should be referred to or the Equality and Diversity Co- ordinator should be contacted.